Rectification cannot be used as review: section 154 cannot reopen a concluded matter or revisit an already decided issue.

Rectification under section 154 is confined to correcting a mistake apparent from the record and cannot be used to reopen a concluded matter or function as a review. Where the Assessing Officer sought to revisit an issue already decided, the exercise exceeded the limited scope of rectification jurisdiction and amounted to an impermissible de facto review. The rectification order was therefore invalid and was quashed, with the assessee succeeding.

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Issues: Whether the Assessing Officer could invoke rectification jurisdiction under section 154 to undo a concluded order, and whether the impugned rectification amounted to an impermissible review.

Analysis: Rectification under section 154 is confined to correcting a mistake apparent from the record and cannot be used as a substitute for review. The impugned action was directed at revisiting a matter already concluded and therefore exceeded the limited scope of rectification jurisdiction. A de facto review by resort to section 154 is not legally permissible.

Conclusion: The rectification order was invalid and was quashed, with the result that the assessee succeeded.

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